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Wood v Holden

 
Now that the Court of Appeal decision in this case has become final John Carrell of Farrer & Co considers the lessons for those administering offshore companies
 
Wood v Holden is the first case on the tax residence of a company to be decided by the courts in 45 years and is therefore of momentous importance for practitioners. It concerned an offshore company that took part in a capital gains tax avoidance scheme the question being whether that company was managed and controlled from the UK and therefore resident here.
 
Last November the Court of Appeal ruled in favour of the taxpayers that the company was non-resident. In their article in The Tax Journal Issue No 824 13 February 2006 Andrew Watters and Jonathan...

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